We sympathise with former members of the British Steel Pension Scheme (BSPS) who lost money after they were given unsuitable advice from people they trusted. Complaints are a valuable source of feedback which help us improve and learn. There have also been 4 independent reports into the BSPS since 2018, which have helped us learn lessons. We have accepted several of their recommendations and implemented improvements, including those below.We now have much closer collaboration between the FCA,...
The FCA's response to the Complaint Commissioner's report on the British Steel Pension Scheme addresses systemic failures in pension transfer advice that affected approximately 7,700 members, with 47% receiving unsuitable advice. This statement demonstrates the FCA's acknowledgment of regulatory shortcomings and outlines remedial measures implemented to prevent similar harm, including enhanced inter-agency collaboration, stricter product governance rules, and a £106 million redress scheme now benefiting 1,870 affected members.
What Changed
The FCA has implemented the following regulatory and operational changes in response to BSPS failures:
Enhanced inter-agency collaboration: Closer coordination between the FCA, The Pensions Regulator, Pension Protection Fund, and Money and Pensions Service to improve intelligence sharing on defined benefit (DB) pension transfer risks
Data collection and monitoring: Expanded collection of pension transfer data from advisory firms to proactively identify emerging risks and market trends
Contingent charging ban: Prohibition of contingent charging arrangements for DB pension transfers to...
What You Need To Do
- *For firms that provided DB pension transfer advice:
- *Conduct retrospective suitability reviews of all DB pension transfer advice provided, particularly during 2015-2018, identifying unsuitable recommendations
- *Calculate and pay redress to affected customers to restore them to their pre-transfer financial position, with reference to the FSCS redress methodology
- *Implement enhanced governance for DB pension transfer advice, including:
- Documented suitability assessments with clear rationale
Key Dates
Late 2017 - FCA received initial intelligence about poor pension transfer advice quality
December 2018 - FCA published initial findings showing less than 50% of reviewed advice was suitable
May 2020 - FCA directed 45 firms to conduct suitability assessments (Past Business Reviews)
April 2022 - FCA imposed asset retention rules for DB pension transfers
April 2023 - BSPS redress scheme formally introduced, requiring firms to review advice suitability and pay redress
Compliance Impact
Urgency: HIGH
Wealth ManagerAsset ManagerAll Firms
Policy statement 10/26
PS10/26 finalizes PRA proposals to raise the Resolution Assessment threshold from £50 billion to £100 billion in retail deposits and reduce recovery plan review frequency for Small Domestic Deposit Takers (SDDTs) from annually to biennially, enhancing proportionality in resolution and recovery frameworks post-financial crisis. These changes reduce regulatory burden on smaller firms while maintaining safety and soundness, directly supporting PRA objectives of competitiveness and growth. Compliance teams must assess scope changes immediately to align reporting and planning cycles.
What Changed
Resolution Assessment Threshold: Increased from £50 billion to £100 billion in retail deposits, limiting reporting and disclosure requirements under the Resolution Assessment Part of the PRA Rulebook to only the largest firms posing systemic risks.
Recovery Plans Review Frequency: For SDDTs and SDDT consolidation entities, reduced from at least annually to at least every two years, aiming for higher quality plans with less frequent reviews.
Rulebook and Guidance Updates: Amendments to Resolution Assessment Part (Appendix 2), Recovery Plans Part (Appendix 3), and Supervisory Statement SS9/17 –...
What You Need To Do
- Scope Assessment
- Recovery Plans
- Reporting/Disclosure
Key Dates
1 April 2026 - Effective date for PS10/26 changes, including new £100bn threshold and biennial recovery plan reviews for SDDTs .
2 October 2026 - Expected submission date for first Resolution Assessment reports for in-scope firms (as previously communicated by PRA) .
11 June 2027 - Expected publication date for first disclosures under amended threshold .
Compliance Impact
Urgency: High – Effective 1 April 2026 (imminent from March 2026), with first reports due 2 October 2026; firms between £50-100bn retail deposits gain immediate burden relief (exiting scope), while largest firms face no new burdens but must confirm ongoing compliance. Matters due to proportionality aligning with PRA growth objectives, reducing costs for mid-tier banks/building societies amid economic pressures, but requires swift deposit recalibration to avoid inadvertent non-compliance.
Bank
Policy statement 11/26
PS11/26 finalizes PRA rules enhancing Pillar 3 disclosures on resolvability resources (MREL), capital distribution constraints (CDCs), and disclosure basis for UK banks and building societies. It matters because it standardizes information to boost market discipline, user comparability, and confidence in orderly resolution, directly impacting financial stability and compliance reporting. No substantive changes from CP16/25 consultation, with minor clarifications only.
What Changed
Standardized MREL disclosure templates: Replaces free-form disclosures with four new templates aligned to Basel BCBS TLAC formats (adapted for UK), expanding scope to more firms for consistency on MREL adequacy.
Qualitative CDC narrative: Added to UK CC1 template for firms subject to CDCs, enabling market assessment of restriction impacts; removes obsolete Systemic Risk Buffer (SRB) disclosure post-O-SII buffer replacement.
Disclosure basis statement: Firms must specify their Pillar 3 regime (e.g., resolution entity, O-SII, large institution), frequency, and details like reference date,...
What You Need To Do
- Update Pillar 3 processes to use new MREL templates (Annex XXVII instructions), UK CC1 with CDC narrative, and basis statement (e
- For CDC-subject firms
- Ensure semi-annual disclosure of key metrics (Article 447 points a-g) where required
- Integrate into consolidated reporting for UK parents; test templates/instructions from appendices
- Review for alignment with broader CRR changes (e
Key Dates
17 March 2026 - PS11/26 and accompanying rule instruments (e.g., Disclosure (CRR) Instrument 2026) published.
1 January 2027 - Policy effective date; rules apply from this date.
H1 2027 - First disclosures under new policy published, covering period ending **31 December 2026** (annual/semi-annual as applicable).
Compliance Impact
Urgency: High – Effective 1 January 2027 requires immediate template/system updates for H1 2027 disclosures (year-end 2026 data), with standardized formats limiting flexibility and raising non-compliance risks to market discipline objectives. Impacts reporting teams, resolution planning, and investor relations; proportional design minimizes burden but demands proactive gap analysis given no transition grace beyond effective date.
BankBroker DealerAll Firms
Policy statement 9/26
PS9/26 finalizes targeted amendments to MREL reporting templates, including changes to MRL001 and MRL003 data elements and the deletion of MRL002, reducing reporting burdens while maintaining resolution planning oversight. This matters for compliance teams as it streamlines processes under the PRA's Future Banking Data programme, with implementation from 1 January 2027, enabling firms to reallocate resources efficiently.
What Changed
Amendments to data elements in the MREL resources template (MRL001) and MREL debt template (MRL003), with full deletion of the MREL resources forecast template (MRL002).
Consequential updates to reporting instructions (Appendix 2) and Supervisory Statement SS19/13 (Appendix 3), including relocation of instrument scope descriptions to reporting instructions for clarity.
No changes to quarterly reporting frequency for MRL001/MRL003, despite industry requests for semi-annual alignment, to ensure monitoring of loss-absorbing capacity.
PRA to publish updated reporting taxonomy shortly.
What You Need To Do
- Review and update internal reporting systems to incorporate revised MRL001/MRL003 templates and deleted MRL002 by 1 January 2027
- Implement updated reporting instructions and SS19/13 amendments, including clarified scope of instruments in MRL templates
- Prepare for Q4 2026 data submission in February 2027 using new taxonomy (to be published shortly by PRA)
- For firms with deleted COREP13 templates, cease submissions from April 2026 cycle
- Conduct gap analysis against SS19/13 changes and test processes for quarterly MREL reporting continuity
Key Dates
1 January 2027 - Revised MRL001 and MRL003 templates effective; first submissions of 2026 Q4 data (ending 31 December 2026) due in **February 2027**. DEADLINE
1 April 2026 - Partial revocation of UKTS 2018/1624 (COREP13), deleting certain templates ahead of April 2026 cycle for period ending 31 December 2025.
1 April 2026 - PS10/26 effective (related: Resolution Assessment threshold amendments, reports due 2 October 2026). DEADLINE
1 January 2027 - PS11/26 effective (related: disclosures from 2027 H1 for period ending 31 December 2026).
Compliance Impact
Urgency: Medium – Changes reduce burden (net simplification, ~25% per industry feedback) but require system updates before 1 January 2027 submissions; non-compliance risks resolution planning scrutiny, though lead time mitigates immediate pressure. Matters for maintaining accurate MREL monitoring amid PRA's FBD efficiency drive.
Bank
We will set out our approach on motor finance redress shortly after markets close on Monday 30 March, having consulted on a compensation scheme in October 2025.
The FCA is scheduling its announcement on a proposed motor finance redress scheme—addressing historical commission disclosure failures in car loans—for shortly after markets close on Monday, 30 March 2026, following a consultation launched in October 2025. This matters because it signals imminent final rules that could impose up to GBP11 billion in costs on lenders, affecting millions of consumers and requiring urgent operational preparations to ensure timely payouts in 2026.
What Changed
Introduction of a 3-month implementation period for most firms, extendable to 5 months for older motor finance agreements, to handle the scheme's scale and complexity.
Streamlined consumer journey: Pre-scheme complainants no longer need to opt out; lenders must notify them of owed compensation within 3 months post-implementation, with immediate acceptance options available.
Removal of mandatory recorded delivery for customer communications, allowing flexible channels with fraud safeguards.
No final decision yet on proceeding, but likely modifications based on over 1,000 consultation...
What You Need To Do
- Review and prepare systems
- Monitor complaints
- Assess provisions
- Compliance checks
- Stakeholder engagement
Key Dates
October 2025 - Consultation on compensation scheme launched .
30 March 2026 (shortly after markets close) - FCA to publish final rules/approach on motor finance redress .
~June 2026 (3 months post-announcement) - End of standard implementation period; lenders notify consumers of redress .
~August 2026 (5 months for older agreements) - Extended implementation deadline .
~September 2026 (3 months post-implementation) - Consumers informed of compensation amounts .
Compliance Impact
Urgency: High – With the announcement just 6 days away (as of 24 March 2026), firms have minimal time to finalize preparations amid GBP11 billion cost risks, market disruption warnings, and lender pushback; delays could amplify redress delays, fines, or consumer harm claims.
BankPayment ProviderAll Firms
We are reminding regulated firms they need to undertake proper checks when dealing with unregulated lenders, safe custody providers, money brokers and financial leasing companies – also known as 'Annex 1' firms. There are around 1,200 of these firms registered with us for solely anti-money laundering purposes. Our powers are currently limited to looking at how these firms are meeting their anti-money laundering obligations and they are not subject to our wider rulebook. This regime is based o...
The FCA statement reminds regulated firms to perform robust due diligence on 'Annex 1' firms—unregulated lenders, safe custody providers, money brokers, and financial leasing companies registered solely for AML purposes—due to their limited oversight and heightened financial crime risks. This matters because Annex 1 firms (approx. 1,200) are not subject to FCA's full rulebook, conduct rules, or protections like the Financial Ombudsman Service, exposing regulated firms to contagion risks if they fail to manage interactions properly. Non-compliance could lead to regulatory scrutiny, enforcement, or reputational damage amid FCA's ongoing AML focus.
What Changed
No new rules or legislative changes are introduced; this is a supervisory reminder reinforcing existing obligations under the Money Laundering Regulations 2017 (MLRs). It emphasizes enhanced due diligence on Annex 1 firms, referencing the 2025 National Risk Assessment (NRA) for risk management. The FCA highlights proactive engagement, including a 2024 letter to CEOs and follow-up with 300 firms in late 2025, signaling intensified supervision without altering the registration-only regime under the Financial Services and Markets Act.
What You Need To Do
- Verify Annex 1 registration status directly from the firm and via independent checks (e
- Understand the Annex 1 firm's business model, products, and risks, aligning with MLRs and 2025 NRA
- Manage identified risks, such as AML deficiencies or consumer encouragement into limited company structures for unregulated lending
- Document due diligence to demonstrate compliance, integrating into broader financial crime frameworks (e
Key Dates
2024 - FCA letter to CEOs of Annex 1 firms raising AML concerns. - **Late 2025 - FCA follow-up engagement with 300 Annex 1 firms.**
Compliance Impact
Urgency: High – This amplifies existing AML due diligence requirements amid FCA's 2025-30 financial crime strategy, with evidence of supervisory action (2024 letter, 2025 follow-ups). Failure risks enforcement, as Annex 1 interactions could facilitate financial crime or consumer harm without FOS protections; firms should audit exposures immediately to align with BWRA/CRA expectations and avoid findings like those in FCA's risk assessment review.
BankPayment ProviderAll Firms
We have opened an enforcement investigation into Market Financial Solutions Limited (MFS). MFS is an Annex 1 business, which is solely registered with and supervised by us for its compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.Annex 1 registered firms are not authorised or subject to wider FCA regulation.MFS entered administration on 25 February 2026.
The FCA has opened an enforcement investigation into Market Financial Solutions Limited (MFS) following the firm's entry into administration on 25 February 2026, amid allegations of serious financial irregularities, fraud, and double-pledging of collateral. This investigation is significant because it represents regulatory scrutiny of an Annex 1 business—a firm with limited FCA oversight—whose collapse exposed structural weaknesses in private credit markets and raised questions about due diligence practices across the financial sector.
What Changed
The FCA's enforcement investigation does not introduce new regulatory requirements but rather represents the regulator's response to alleged breaches of existing obligations. The key regulatory framework under which MFS is being investigated is:
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017: MFS's primary regulatory obligation as an Annex 1 registered firm.
What You Need To Do
- *For MFS and its Administrators
- Cooperate fully with the FCA enforcement investigation
- Preserve all documentation related to AML/CTF compliance, customer due diligence, and transaction monitoring
- Provide access to bank accounts, transaction records, and compliance files to investigators
- Respond to FCA information requests within specified timeframes
Key Dates
25 February 2026 - MFS entered administration
20 March 2026 - FCA enforcement investigation opened (current date context)
No specific deadline provided for investigation completion or enforcement action
Compliance Impact
Urgency: CRITICAL
BankAll Firms
Policy statement 7/26
PS7/26 finalizes PRA rules for standardized reporting of operational incidents and material third-party (MTP) arrangements, responding to CP17/24 consultation feedback by reducing firm burden through simplified templates and exclusions. This matters for compliance professionals as it enhances PRA oversight of operational resilience risks amid rising threats and third-party reliance, aligning with international standards like DORA and FSB FIRE while supporting identification of critical third parties (CTPs).
What Changed
MTP Reporting: Amended notification rule for clarity; scope excludes credit unions with <£50m assets and all third-country branches; separated register and notification templates with reduced data fields; single submission platform (FCA Connect).
Operational Incident Reporting: Merged three-phased reports (initial, interim, final) into one simplified, aligned template across PRA/FCA/Bank; removed fields, made more optional; clarified thresholds (e.g., safety/soundness, financial stability, policyholder protection for PRA), timing, and factors like contagion/reputation via SS1/26.
Guidance...
What You Need To Do
- Identify and notify MTP arrangements via FCA Connect (excluding exemptions); maintain annual register with reduced fields
- Monitor/assess operational incidents against clarified thresholds (e
- Update policies per SS1/26 (thresholds) and SS2/21 (MTP identification)
- Align reporting with PRA/FCA/Bank templates; use data for resilience prioritization
- For insurers
Key Dates
December 2024 - CP17/24 consultation published.
H1 2026 - Final PRA/FCA rules on operational incident and third-party reporting effective (per industry analysis).
30 working days post-incident resolution - Submit final incident report update (extendable to 60 working days in complex cases).
Annual - MTP register reporting (exact date not specified; aligns with notifications).
March 2026 implies rules near/applicable now; implementation likely immediate or phased per PS.)
Compliance Impact
Urgency: High - Mandates new reporting infrastructure and processes amid rising operational threats; non-compliance risks supervisory action on resilience vulnerabilities. Reduced burden from CP mitigates costs, but timely implementation critical for PRA oversight and CTP identification; benefits (e.g., thematic analysis) outweigh costs per PRA.
BankInsuranceAll Firms
Policy statement 6/26
PS6/26 finalizes the PRA's policy on recognized exchanges (REs) under Article 4(1)(72)(c) of the UK CRR, shifting responsibility to firms for assessing exchange and asset liquidity conditions while restating main indices in the PRA Rulebook and revoking SS20/13. This matters for PRA-regulated firms as it enables more dynamic, risk-sensitive capital treatments for traded assets, potentially expanding eligible REs and supporting competitiveness without PRA pre-approval.
What Changed
New Recognised Exchanges (CRR) Part in the PRA Rulebook: Specifies conditions for REs focusing on (i) exchange/market structure risk (e.g., operational robustness of clearing/settlement) and (ii) asset liquidity risk; firms must assess and document compliance.
Restatement of main indices: List from Commission Implementing Regulation 2016/1646 moved to PRA Glossary without policy changes.
Amendment to 'higher risk equity exposure' definition: Aligns with Basel 3.1 near-final rules, excluding qualifying listed equities from higher risk weights under the standardized approach (ties to exchange...
What You Need To Do
- Assess exchanges/assets
- Update policies/systems
- Review exposures
Key Dates
18 June 2025 - Consultation deadline for CP3/25 (closed; feedback incorporated in PS6/26). DEADLINE
1 July 2026 - Implementation date for new RE rules, main indices restatement, SS20/13 revocation, and related Rulebook amendments.
1 January 2027 - Proposed implementation for Basel 3.1 changes, including higher risk equity exposure amendments (alongside broader standards).
Compliance Impact
Urgency: High – Effective 1 July 2026 (approx. 4 months from now), requiring immediate gap analysis, policy updates, and assessor training to avoid capital miscalculations or supervisory findings. Impacts prudential calculations directly, with flexibility reducing PRA burden but increasing firm accountability and review risks.
Bank
We'd also streamline the scheme, so millions get compensation in 2026. We're considering over 1,000 responses to our proposals for a compensation scheme for motor finance customers who were treated unfairly.If we proceed with a scheme, we are likely to make several changes. If we do go ahead, we expect to publish final rules in late March. The timing of publication will be outside market hours and we'll confirm the date in advance. Final decisions on the scheme have not yet been made. But to ...
The FCA is implementing a **streamlined motor finance compensation scheme** to address unfair commission disclosure practices, with final rules expected in late March 2026 and scheme launch in early 2026. This represents a major regulatory intervention affecting approximately 14 million motor finance agreements with estimated total redress costs of £8.2 billion, requiring immediate operational preparation by all lenders and finance providers.
What Changed
The FCA's streamlined approach introduces several material modifications to the original compensation scheme proposal:
*Process Streamlining
Automatic opt-in for prior complainants: Customers who complained before scheme launch will no longer be asked to opt out. Instead, lenders must notify them of compensation eligibility within three months of the implementation period ending.
Immediate acceptance of offers: Consumers can accept redress offers immediately rather than waiting for final determinations.
Flexible communication channels**: Firms are no longer required to use recorded delivery;...
What You Need To Do
- *Immediate Priorities (Q1 2026)
- *Data Integrity Assessment
- *Redress Calculator Development
- Repricing loans based on proposed APR reductions
- Calculating compensatory interest at BoE base rate + 1%
Key Dates
31 May 2026 – Motor finance complaints handling pause lifts; firms must be ready to respond to complaints outside the scheme DEADLINE
Late March 2026 – FCA to publish final scheme rules (timing to be confirmed in advance, outside market hours)
Early 2026 – Scheme implementation begins (exact date dependent on final rules publication)
Three months from scheme launch – Standard implementation period for lenders to contact prior complainants and provide compensation notifications
Five months from scheme launch – Extended implementation period for older agreements
Compliance Impact
Urgency: CRITICAL
BankFintechAll Firms
We are bringing forward a review of some aspects of the UK Listing Rules to consider how they apply to specific types of investment entities. As part of the Primary Markets EffectivenessReviewwe explored which types of investment entities could be eligible to be listed. Since introducing the new listingruleswe have heard from stakeholders that these eligibility criteria, particularlyregardingrisk-spreading, may be unduly restrictive. We will use this review to assess if changes should be made...
The FCA is conducting a targeted review of UK Listing Rules applicable to investment entities, with particular focus on whether current risk-spreading eligibility criteria are unduly restrictive and how rules support shareholder rights and conflict management. This review represents a potential material shift in listing accessibility for alternative investment funds and closed-ended investment vehicles, with final proposals expected by end-2026.
What Changed
The FCA's review addresses three primary areas:
*Risk-Spreading Eligibility Criteria**
Stakeholders have flagged that current risk-spreading requirements in the new listing rules may be overly restrictive for certain investment entity types. The FCA will assess whether modifications are warranted to broaden eligibility for investment entities seeking primary market access.
*Shareholder Rights and Board Governance**
The review will examine how listing rules, in conjunction with company law, ensure boards adequately support shareholder rights, facilitate shareholder engagement, and manage...
What You Need To Do
- *Immediate (Q1 2026)
- *Monitor FCA consultation announcements for publication of the consultation paper on listing rules modifications
- *Assess current compliance posture against existing risk-spreading criteria to identify potential gaps or restrictive elements
- *Document shareholder engagement frameworks and conflict-of-interest management procedures to prepare for governance review
- *During consultation period
Key Dates
End of 2026 - FCA to complete review and issue final rules
Q2 2026 (estimated) - Consultation paper publication (FCA indicates "proposals in a consultation paper" without specific date, but typical FCA consultation windows are 8-12 weeks)
H2 2026 - Final rules expected following consultation period
Compliance Impact
Urgency: HIGH
Asset ManagerHedge Fund
The Securities and Exchange Commission today adopted final rule and form amendments to reflect the requirements of the recently enacted Holding Foreign Insiders Accountable Act (HFIA), which will increase transparency into the holdings and transactions…
The SEC adopted final rules on February 27, 2026, implementing the Holding Foreign Insiders Accountable Act (HFIA), which extends Section 16(a) beneficial ownership reporting requirements to directors and officers of foreign private issuers (FPIs) with Exchange Act Section 12-registered equity securities, effective March 18, 2026. This aligns FPI insiders' disclosure obligations with those of U.S. domestic issuers, enhancing market transparency while exempting >10% holders from reporting. Compliance professionals must prioritize preparation as the deadline approaches in two weeks from today (March 3, 2026).
What Changed
Extension of Section 16(a) Reporting: Directors and officers of FPIs must now file Forms 3 (initial beneficial ownership), 4 (changes in ownership), and 5 (annual summary) electronically and in English, covering holdings and transactions in the FPI's equity securities.
Rule Amendments:
- Rule 3a12-3(b): Removes full Section 16 exemption for FPI insiders; retains exemptions only for Section 16(b) short-swing profits and Section 16(c) short-selling prohibitions.
- Rule 16a-2: Explicitly excludes >10% beneficial owners of FPI equity from Section 16(a) reporting.
Form Updates: Forms 3, 4, and...
What You Need To Do
- For FPIs and Insiders
- Training and Policies
- Systems Preparation
- Monitor Exemptions
Key Dates
December 18, 2025 HFIA enacted into law.
February 27, 2026 SEC adopts final rules (ahead of 90-day mandate).
March 18, 2026 Effective date; directors/officers of existing FPIs must file initial Form 3; new directors/officers file within 10 days of appointment; ongoing Forms 4 within 2 business days of transactions. DEADLINE
Ongoing Annual Form 5 for unreported transactions; adopting release published in Federal Register (date TBD).
Compliance Impact
Urgency: Critical – With the March 18, 2026, effective date just two weeks away (as of March 3, 2026), non-compliance risks SEC enforcement, including public disclosure failures and potential civil penalties under Section 16. This materially heightens governance burdens for FPIs, demands immediate system/process overhauls, and aligns foreign insiders with U.S. standards to prevent opacity in cross-border listings.
All Firms
The Payments Vision Delivery Committee (the Committee) has published the Payments Forward Plan (the Plan). Read the Plan on GOV.UKThe Committee comprises:HM TreasuryBank of EnglandFinancial Conduct AuthorityPayment Systems RegulatorThe Plan sets out upcoming initiatives across retail and wholesale payments, including elements of digital assets. Recent publications on open banking, stablecoins and contactless limits, alongside the initiatives in the Plan, show the high level of activity across...
The Payments Vision Delivery Committee—comprising HM Treasury, Bank of England, FCA, and Payment Systems Regulator—has published the **Payments Forward Plan**, a three-year regulatory roadmap for retail, wholesale payments, and digital assets, aligning with the UK's National Payments Vision for a trusted, innovative ecosystem. This matters for compliance teams as it provides sequencing and milestones for multiple initiatives, enabling proactive planning amid high regulatory activity, including PSR consolidation into FCA and infrastructure upgrades. It signals coordinated efforts to boost competition, resilience, and innovation while minimizing sector capacity strain.[FCA publication]
What Changed
No immediate binding regulatory changes are imposed by the Plan itself; it is a forward-looking roadmap outlining planned initiatives rather than new rules. Key elements include:
Modernisation of payments framework: Consolidation of PSR into FCA, with HMT consultation response in Q1 2026; data/operational enhancements to Faster Payments and Bacs by end-2026.
Infrastructure upgrades: Short-term resilience improvements to Faster Payments and Bacs (end-2026); exploration of regulated stablecoins for on-chain settlement (H1 2026).
Safeguarding enhancements: FCA Supplementary Regime effective May...
What You Need To Do
- Review the full Plan on GOV.UK (https
- Engage proactively
- Stablecoin firms
- Monitor and plan
- Internal audit
Key Dates
Q1 2026 - HMT consultation response on PSR consolidation into FCA .
Jan-Apr 2026 - FCA engagement with sector on Supplementary Safeguarding Regime .
Feb-Mar 2026 - Independent assessment of proposals for standards setting body .
Spring 2026 - HMT update on Consumer Credit Act reform .
18 January 2026 - Deadline for stablecoin issuers to apply to FCA regulatory sandbox (related push for innovation).
Compliance Impact
Urgency: Medium. This is a planning document, not enforceable rules, but its milestones trigger near-term actions (e.g., Q1 2026 engagements, May 2026 safeguarding). It matters because it coordinates high-activity areas like PSR-FCA merger and stablecoins, reducing surprises but demanding resource allocation for innovation/resilience amid sector capacity constraints. Firms delaying review risk missing input opportunities or readiness gaps, especially with VRP/stablecoin momentum.
Payment ProviderFintechBank
We have signed a Memorandum of Understanding (MoU) with the Independent Football Regulator (IFR). The MoU establishes how the 2 organisations will work together and support effective regulation where football and financial services intersect.It also sets out a high-level framework for principles for cooperation between the IFR and the FCA.Read the MoU (PDF)
The FCA has signed a Memorandum of Understanding (MoU) with the newly established Independent Football Regulator (IFR) to define cooperation on regulating intersections between football clubs and financial services, such as ownership suitability, licensing, and financial sustainability. This matters for compliance professionals as it formalizes information sharing and joint oversight, potentially impacting firms involved in football-related financing, investments, or consumer credit products tied to sports. It supports the Football Governance Act 2025 framework, enhancing regulatory alignment where financial misconduct could affect club operations.[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
What Changed
Establishes a high-level framework of principles for cooperation between FCA and IFR, focusing on effective regulation at the football-financial services nexus.
Outlines how the organizations will work together, including information sharing on matters like club owners' financial dealings, licensing compliance, and enforcement where financial services intersect with IFR's duties (e.g., suitability tests for owners/officers, financial resources thresholds).[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
Builds on prior MoUs (e.g., FCA-UKGC models) by addressing...
What You Need To Do
- Review and map exposures
- Enhance information sharing protocols
- Incorporate IFR factors in due diligence
- Monitor joint enforcement
Key Dates
Act 2025 implementation).[https://www.fca.org.uk/news/statements/mou-independent-football-regulator-fca]
2025 - Football Governance Act 2025 enactment Establishes IFR statutory powers, including provisional/full club licensing from this date onward.
Ongoing - IFR licensing rollout Clubs transition from provisional to full licenses once threshold conditions (e.g., financial resources, owner suitability) met; no fixed end-date.
Compliance Impact
Urgency: Medium – This MoU does not impose new binding rules or deadlines but signals heightened cross-regulator focus on football finances post-Football Governance Act 2025, risking enforcement overlaps or info requests. It matters for firms with niche exposures (e.g., sports financing) to avoid gaps in owner due diligence or financial promotions, potentially amplifying AML/conduct risks amid IFR's divestment powers.
BankFintechPayment Provider
ESMA simplifies MiFID II/ MiFIR obligations on market data 23 February 2026 Guidelines and Technical standards Market data Trading The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has withdrawn its guidelines on the MiFID II/ MiFIR obligations on market data , effective immediately, reflecting its ongoing commitment to simplifying rules and reducing unnecessary compliance burdens for market participants. The decision aligns the framewo...
ESMA has immediately withdrawn its guidelines on MiFID II/MiFIR market data obligations to align with the new Regulatory Technical Standards on making market data available on a reasonable commercial basis (RTS on RCB), reducing compliance burdens for market participants. This simplifies the regulatory framework by eliminating overlapping soft-law guidance, focusing firms on binding RTS requirements for data transparency, non-discrimination, and cost-based pricing. It matters as it streamlines operations amid broader MiFID II/MiFIR reviews, lowering costs while maintaining market integrity.
What Changed
Withdrawal of ESMA's previous guidelines on MiFID II/MiFIR market data obligations, effective immediately on 23 February 2026, to avoid overlap with binding rules.
Full alignment with RTS on RCB, which sets criteria for transparency, non-discrimination, and reasonable commercial basis pricing of market data by trading venues and approved publication arrangements.
Firms must now rely solely on RTS legal text for interpreting data provision, disclosure, and fee structures, without legacy interpretive guidance.
What You Need To Do
- Review and map internal policies, procedures, and data disclosure practices directly to RTS on RCB criteria for transparency, non-discrimination, and cost-based pricing
- Document compliance with RTS across asset classes and distribution channels; cease reliance on withdrawn guidelines
- Contact ESMA at RCB@esma
Key Dates
23 November 2025 - RTS on RCB enters into force.
23 February 2026 - Withdrawal of legacy ESMA guidelines takes effect immediately.
22 August 2026 - End of transition period for pre-authorised market data providers to align contracts with RTS on RCB.
Compliance Impact
Urgency: High - Immediate guideline withdrawal requires prompt policy updates to avoid supervisory misalignment, though the 22 August 2026 transition eases contract changes for legacy providers. This matters as it reduces ambiguity and burdens in a simplifying regulatory environment, but non-compliance risks enforcement under binding RTS amid MiFID II/MiFIR reviews; proactive alignment prevents future disruptions.
Broker Dealer
Policy statement 5/26
PRA Policy Statement PS5/26 finalizes rules permitting UK credit unions to invest in Credit Union Service Organisations (CUSOs), expanding from the CP13/25 proposals to foster innovation, collaboration, and growth while managing prudential risks through safeguards like due diligence and investment caps. This matters as it enables credit unions—often smaller mutuals—to access shared services (e.g., HR, IT, compliance) via CUSOs, leveling the playing field against larger competitors and supporting the PRA's safety/soundness and competitiveness objectives.
What Changed
Investment permission and cap increase: Credit unions can now invest in CUSOs using own capital, with the cap raised from 5% to 7.5% of total capital across all CUSOs (clarifications added on practical application, e.g., aggregation).
Expanded CUSO scope: CUSOs can now serve other UK-regulated mutuals (with Part 4A permission) beyond just credit unions; partnerships with non-credit unions permitted as owners, subject to safeguards.
Supervisory expectations in SS2/23: New chapter requires due diligence, risk analysis, limited liability to investment amount, legal/operational separation,...
What You Need To Do
- Review and update policies
- Ensure structural safeguards
- Governance alignment
- Implementation planning
- Reporting/oversight
Key Dates
24 October 2025 - Consultation response deadline for CP13/25. DEADLINE
20 February 2026 - Publication date of PS5/26 (final policy).
~20 August 2026 - Implementation deadline for SS2/23 CUSO expectations (six months from PS5/26 publication). DEADLINE
Compliance Impact
Urgency: High – Credit unions eyeing CUSOs for growth (e.g., shared services) must act promptly within the six-month window to avoid supervisory breaches, as this expands opportunities but introduces new prudential risks (e.g., ownership misalignment, capital exposure). Non-compliance risks heightened PRA scrutiny, especially post-PS26/25 mutual sector review; benefits justify costs only for opt-in firms, but proactive preparation ensures safety/soundness.
BankFintechAll Firms
Our clarification about forbearance following the introduction of the new Public Offers and Admissions to Trading Regulations (POATRs) regime. On 19 January 2026, the Public Offers and Admissions to Trading Regulations (POATRs) regime and associated changes to our listing processes in the UK Listing Rules (UKLR) came into force. These changes introduced a requirement in the Prospectus Regime Manual (PRM 1.6.4R) for issuers to notify a Regulatory Information Service (RIS) of any admission to t...
The FCA's statement clarifies forbearance on overlapping notification requirements for admissions to trading under the new POATRs regime effective 19 January 2026, addressing confusion from removed block listing exemptions in UKLR. It matters because it provides temporary relief from duplicative RIS notifications for frequent issuers, preventing unintended supervisory burdens while the FCA consults on rule amendments.
What Changed
POATRs and UKLR Updates: Effective 19 January 2026, PRM 1.6.4R requires issuers to notify a Regulatory Information Service (RIS) of any admission to trading within 60 days, allowing grouping of multiple admissions for proportionality.
Overlapping UKLR Rules: Provisions in UKLR 6.4.4R(4), 13.3.20R(4), 14.3.17R(4), 16.3.16R(4), and 22.2.17R(4) require "as soon as possible" RIS notifications for new equity issues or public offers, conflicting with the 60-day rule post-block listing deletion (former UKLR 20.6).
Forbearance Policy: FCA will not take enforcement action for non-compliance with the...
What You Need To Do
- Review ongoing/future issuances against former block listing criteria: confirm securities unissued pre-19 January 2026 and same purpose to rely on forbearance
- Implement PRM 1.6.4R
- Monitor FCA announcements for consultation launch and updates; prepare responses if issuing frequently
- Document reliance on forbearance (e
- No immediate "as soon as possible" notifications needed under forbearance for qualifying cases
Key Dates
19 January 2026 - POATRs regime and UKLR changes effective, including PRM 1.6.4R (60-day RIS notification) and deletion of UKLR 20.6 block listings.
19 January 2026 - Cut-off for securities under former block listings to qualify for forbearance (must not have been issued/offered prior). DEADLINE
Shortly after February 2026 - FCA consultation on removing UKLR 6.4.4R(4) and equivalents (no exact date specified).
Compliance Impact
Urgency: Medium - Forbearance reduces immediate risk of enforcement for qualifying issuers, but ongoing POATRs compliance (60-day notifications) is mandatory. Matters for operational efficiency, as misalignment could lead to duplicative reporting costs; non-qualifying issuances risk breaches until consultation resolves.
All Firms
We have signed an Exchange of Letters with the International Financial Services Centres Authority (IFSCA). IFSCA is the unified regulator for financial institutions operating in Gujarat International Finance Tec-City (GIFT City), India’s first international financial services centre.This agreement affirms both authorities’ commitment to develop our regulatory relationship.Download our letter (PDF)The letters set out the intention to share regulatory knowledge and best practice to support the ...
The FCA has signed an Exchange of Letters with India's IFSCA, the regulator for GIFT City, to foster regulatory cooperation, knowledge sharing, and stronger links between UK financial markets and GIFT City. This matters for compliance professionals as it signals expanding cross-border ties, potentially easing market access and harmonizing standards for firms operating between the UK and India, amid the FCA's broader global outreach strategy. No binding rules are imposed, but it sets the stage for future alignment in areas like fintech and financial services.
What Changed
There are no direct regulatory changes or new requirements imposed by this Exchange of Letters. It is a non-binding agreement focused on:
Sharing regulatory knowledge and best practices.
Supporting financial services development in both jurisdictions.
Promoting links between GIFT City and UK markets.
The letters affirm commitment to developing the regulatory relationship, with an additional step of posting an FCA Financial Services Attaché to the British Deputy High Commission in Mumbai later in 2026 [FCA publication].
What You Need To Do
- binding nature
- Review and download the full Exchange of Letters (PDF available via FCA site) to understand shared priorities
- Assess current India/GIFT City exposures and prepare for potential future information-sharing requests or aligned standards
- Monitor FCA news for follow-up developments, such as joint guidance on fintech or market access https://www
- Engage with FCA international teams if planning cross-border activities in GIFT City
Key Dates
Later in 2026 - Posting of FCA Financial Services Attaché to British Deputy High Commission in Mumbai to support regulatory relationship development [FCA publication].
Compliance Impact
Urgency: Low - This is a cooperative MoU-style letter exchange without immediate rules, penalties, or obligations, posing minimal disruption risk. It matters strategically for long-term planning, as it could lead to simplified compliance for UK-India activities (e.g., reduced dual-regulation friction) and aligns with FCA's pattern of global pacts that indirectly shape supervisory expectations. Firms with India exposure should note it for horizon scanning, but no urgent resourcing is needed.
BankFintechAll Firms
FCA v Huobi Global S.A. and Others. On 21 October 2025, the FCA commenced proceedings in the Chancery Division of the High Court against the following parties:HUOBI GLOBAL S.A.(a company incorporated in Panama)PERSONS UNKNOWN (who are the owner of, controller and/or the persons currently in control of all or part of www.htx.com and/or its associated mobile applications (“the HTX Exchange”))PERSONS UNKNOWN (who are the legal and/or natural persons defined as the HTX Operators in the HTX Platfo...
The FCA has initiated civil proceedings in the High Court against Huobi Global S.A. (HTX, formerly Huobi) and multiple categories of "Persons Unknown" for unlawfully promoting cryptoasset services to UK consumers without authorisation, breaching the financial promotions regime. This action underscores the FCA's aggressive enforcement against unauthorised crypto entities targeting UK retail investors, signaling heightened scrutiny on overseas platforms. Compliance teams must note this as evidence of the regulator's willingness to pursue novel legal strategies like "Persons Unknown" claims to enforce compliance extraterritorially.[https://www.fca.org.uk/news/statements/htx-huobi-legal-proceedings]
What Changed
This is not a policy change but an enforcement action highlighting existing requirements under the UK's financial promotions regime (effective October 2023 for cryptoassets), which mandates FCA registration under anti-money laundering (AML) rules and compliance with promotion standards for all firms—domestic or foreign—marketing to UK consumers. Key elements include prohibitions on unauthorised promotions, with the FCA now using High Court proceedings to target operators, owners, controllers, and even future controllers up to 31 October 2028.
What You Need To Do
- Immediate audit
- Self-identification
- Compliance checks
- Social media monitoring
- Documentation
Key Dates
21 October 2025 - FCA commences proceedings via Claim Form in Chancery Division, High Court.
2 October 2025 - Particulars of Claim dated (note: precedes claim form, likely preparatory).
22 October 2025 - Application Notice for service out of jurisdiction/alternative means.
4 February 2026 - High Court (Deputy Master Dovar) grants permission to serve proceedings out of jurisdiction and by alternative means.
31 October 2028 - Cut-off for "Persons Unknown" category covering new owners/controllers/promoters.[https://www.fca.org.uk/news/statements/htx-huobi-legal-proceedings]
Compliance Impact
Urgency: High - This sets a precedent for extraterritorial enforcement via "Persons Unknown" claims, extending liability to unidentified/future actors, which amplifies risks for non-UK crypto firms. It matters because post-October 2023 rules have seen positive compliance from most, but FCA vows action against outliers, potentially leading to injunctions, fines, or asset freezes; authorised firms face contagion risks via associations.[https://www.fca.org.uk/news/statements/htx-huobi-legal-proceedings]
Crypto ExchangeFintech
We have published a letter to trade associations to provide an update in the development of a Future Entity (FE) for open banking. The letter confirms the appointment of KPMG to provide an independent assessment of proposals to establish a standards-setting body for UK open banking APIs that is capable of becoming the Future Entity. It explains the purpose and scope of the assessment, the respective roles of the FCA, industry, trade associations and the independent assessor, and how firms can...
The FCA has appointed KPMG to conduct an independent assessment of proposals for establishing a **Future Entity** – a standards-setting body for UK open banking APIs that will replace Open Banking Limited. This initiative is critical because it establishes the governance framework for open banking ahead of new legislative powers the FCA will receive under the Data (Use and Access) Act 2025, with a statutory instrument expected by end-2026.
What Changed
The regulatory landscape for UK open banking is undergoing fundamental restructuring:
Transition of regulatory authority: The FCA is becoming the primary regulator for open banking, replacing the Joint Regulatory Oversight Committee (JROC).
Future Entity establishment: A new standards-setting body will become the primary UK standard-setting organization for open banking APIs, responsible for setting and maintaining common standards for minimum service and interoperability, monitoring API performance, and providing directory and certification services.
Independent assessment process: KPMG...
What You Need To Do
- *For industry participants and trade associations
- *Engage with the assessment process
- *Arrange FCA Q&A sessions
- *Coalesce behind proposals
- *Prepare for VRP implementation
Key Dates
February 2026 – Independent assessment process begins; KPMG commences evaluation of proposals
Q1 2026 – Final design of Future Entity expected; live transactions expected through VRP scheme
Before March 2026 – FCA's Open Finance roadmap due for publication DEADLINE
Early April 2026 – KPMG delivers final assessment report; FCA publishes on its website
From April 2026 – Industry and regulators collaborate to progress establishment activity
Compliance Impact
Urgency: HIGH
BankPayment ProviderFintech The FCA and Solicitors Regulation Authority (SRA) are warning claims management companies and law firms (representatives) involved in motor finance claims to make sure clients don’t have multiple representatives for the same claim and are not charged excessive termination fees We have seen some clients with up to 4 different representatives for the same claim. They risk being charged termination fees, which could be deemed excessive, should they try to cancel duplicate agreements.
The FCA and SRA have issued a joint warning to claims management companies (CMCs) and law firms handling motor finance commission claims, addressing multiple client representations (up to 4 per claim observed) and excessive termination fees, which risk unfair consumer treatment. This matters because regulators are intensifying scrutiny amid a paused complaints-handling period (ending May 2026) and a forthcoming redress scheme, with enforcement actions already underway against non-compliant firms.
What Changed
This is a non-binding joint message reinforcing existing obligations under FCA's Consumer Duty, Claims Management Conduct of Business Sourcebook, Consumer Rights Act 2015 (CRA), and SRA standards, rather than introducing new rules. Key emphases include mandatory robust onboarding due diligence to prevent multiple representations, clear upfront disclosure of termination fees, and justification of any fees charged (especially if onboarding was inadequate).
What You Need To Do
- Engaging clients and other representatives to confirm client wishes and establish single representative
- Notifying respondent firms promptly of the sole representative
- Supporting file transfers with client consent and considering no-charge resolutions if onboarding was poor
- Robust onboarding checks (e
- Entering new agreements only after prior termination and informed consent
Key Dates
May 2026 - Current pause on motor finance commission complaints handling ends; non-CRS complaints must progress per DISP timelines. DEADLINE
End of March 2026 - FCA to publish final rules on proposed Motor Finance Consumer Redress Scheme (CRS).
Early 2026 - FCA expected to finalize redress scheme rules (per consultation responses). (https://www.akingump.com/en/insights/alerts/fca-consultation-paper-on-motor-finance-redress-published)
5 February 2026 - FCA launches consumer advertising campaign warning of scammers (post-dated relative to publication).
7 October 2025 - FCA letter to CMCs on related expectations.
Compliance Impact
Urgency: High - Immediate risk of enforcement; FCA/SRA using CRA/DMCA 2024 powers (e.g., info requests from 9 law firms), 5 CMCs paused onboarding, 1 under investigation, SRA closed 7 firms. Matters due to paused complaints (ending soon), impending CRS, consumer harm from fees/delays, and proactive monitoring signaling broader crackdown on HVCC misconduct like excessive fees or poor due diligence.
Payment ProviderAll Firms
We’re working closely with the Office of Financial Sanctions Implementation (OFSI), UK law enforcement, and our regulatory partners to tackle the abuse of cryptoassets and associated money‑laundering activities. Read the full blog on the OFSI’s website.
Crypto ExchangeFintechPayment Provider We have signed a contract with Etrading Software (ETS) to deliver the UK bond consolidated tape. A high-quality tape will provide investors with a comprehensive overview of the bond market and support price formation and liquidity. It will help maintain the UK’s position as a highly competitive and compelling place to invest and grow.ETS has now launched a website that sets out key milestones and provides technical information for data contributors and users. We will continue to support ETS a...
Broker DealerAsset ManagerBank The latest Accelerated Settlement Taskforce (AST) report updates on the significant progress made towards the move to T+1. Read the AST report.Jamie Bell, head of capital markets at the FCA, said:'T+1 marks a major milestone in our drive to support growth and innovation. Faster settlement cycles will reduce risk, free up capital for faster reinvestment and align with other major markets.'We are delighted to see the great progress made last year highlighted in the AST’s report. By the end of t...
Broker DealerBankAsset Manager We have issued a joint statement with the Payment Systems Regulator (PSR) giving clarity on open banking pricing models. We and the PSR have issued the following statement (PDF).This confirms we will not, at this stage, prioritise a Competition Act 1998 (CA98) investigation into the centralised ‘access fee’ pricing model being developed by the UK Payments Initiative (UKPI) for commercial Variable Recurring Payments (cVRPs). cVRPs are an emerging open banking technology that allow consumers to...
The FCA and PSR have jointly confirmed they will not prioritize a Competition Act 1998 investigation into the UK Payments Initiative's (UKPI) centralized access fee pricing model for commercial Variable Recurring Payments (cVRPs), with the CMA's concurrent agreement. This regulatory clarity provides temporary certainty for cVRP development ahead of anticipated legislation by end-2026, creating a critical window for firms to develop compliant commercial models in this emerging open banking technology.
What Changed
The regulatory statement establishes the following key positions:
Non-prioritization of CA98 investigation: The FCA, PSR, and CMA have jointly confirmed they will not prioritize competition law enforcement against UKPI's centralized access fee model for Phase 1/Wave 1 cVRPs (limited to "lower risk" use cases).
Scope limitation: The regulatory clarity applies only to Phase 1/Wave 1 of UKPI's cVRP scheme, specifically addressing lower-risk payment use cases including regulated financial services, utilities, and public sector payments.
Temporary framework: This is explicitly a temporary...
What You Need To Do
- *For UKPI and participating firms
- *Governance documentation
- *Pricing methodology transparency
- *Phase 1/Wave 1 compliance
- *Market engagement
Key Dates
15 January 2026 - FCA and PSR wrote to CMA setting out their non-prioritization position
16 January 2026 - CMA confirmed alignment with FCA/PSR position on CA98 prioritization
20 January 2026 - Joint FCA/PSR statement issued on open banking pricing models
Q1 2026 - Expected first live UKPI cVRP payments
End of 2026 - Government anticipated to introduce legislative framework granting FCA new open banking powers
Compliance Impact
Urgency: HIGH
The FCA and PSR have issued a joint statement providing clarity on open banking pricing models, specifically regarding the centralised 'access fee' pricing model for commercial Variable Recurring Payments (cVRPs). This statement confirms that they will not prioritize a Competition Act 1998 investigation into this model at this stage. The goal is to support the development of cVRPs, giving consumers more control over their payments and lowering processing fees for businesses.
What Changed
The FCA and PSR have clarified their enforcement position on the UKPI's proposal for a commercial model for cVRPs, indicating they will not prioritize a Competition Act 1998 investigation at this stage.
What You Need To Do
- Monitor market developments and updates on the legislative framework for open banking
- Review and understand the implications of the centralised 'access fee' pricing model for cVRPs on your business operations
- Ensure compliance with existing competition laws and regulations
Key Dates
31 Dec 2026 Expected implementation of the government's legislative framework for open banking DEADLINE
1 Jul 2027 End of the temporary measure if the legislative framework is not implemented DEADLINE
Non-Compliance Risk
Enforcement action, fines, or other regulatory penalties for non-compliance with competition laws and regulations
Related Regulations
Competition Act 1998Payment Services Directive (PSD2)
Confidence: high
BankFintechPayment Provider Policy statement 1/26
PS1/26 represents the UK Prudential Regulation Authority's final implementation framework for the Basel 3.1 international banking standards, effective 1 January 2027 (with market risk internal models delayed to 1 January 2028). This policy statement establishes mandatory capital, credit risk, operational risk, and market risk requirements for UK-regulated banks, building societies, and investment firms, addressing post-financial crisis shortcomings in risk-weighted asset (RWA) calculations and capital adequacy frameworks.
What Changed
*Credit Risk Framework**
Implementation of restrictions on Internal Ratings-Based (IRB) approach scope, effective 1 January 2027, with firms required to reclassify certain exposures (e.g., slotting approach IPRE exposures) as High-Volatility Commercial Real Estate (HVCRE) where applicable.
Minor clarifications and amendments to the Standardised Approach and credit risk mitigation techniques.
*Operational Risk**
Updated Business Indicator Component (BIC) calculation methodology requiring inclusion of the current financial year in the three-year average calculation (or an estimate if...
What You Need To Do
- *Immediate (by mid-2026)
- *Conduct impact assessment
- *Review IRB permissions
- *Assess FRTB-IMA readiness
- *Arrange board-level assurance
Key Dates
20 January 2026 – PRA publishes PS1/26 (final rules)
1 January 2027 – Effective date for Basel 3.1 implementation (credit risk, operational risk, reporting/disclosure, IRB scope restrictions, SDDT regime)
1 January 2027 – Interim period begins for FRTB-IMA transition; existing IMA permissions retained; out-of-scope positions move to ASA/SSA
1 January 2028 – FRTB-IMA implementation effective date
2026 ICAAP submission deadline – Must include Basel 3.1/SDDT impact assessment DEADLINE
Compliance Impact
Urgency: HIGH
The Prudential Regulation Authority (PRA) has published the final rules for the implementation of Basel 3.1 standards in the UK, with an effective date of January 1, 2027. The rules aim to enhance the resilience of banks and improve the stability of the financial system. Firms must review and update their policies and procedures to ensure compliance with the new requirements.
What Changed
The PRA has introduced new rules for the calculation of risk-weighted assets, including changes to the credit risk standardised approach, market risk framework, and operational risk requirements. The rules also include amendments to the definitions of probability of default, loss given default, and conversion factor.
What You Need To Do
- Review and update credit risk policies and procedures to ensure compliance with the new standardised approach
- Assess the impact of the new market risk framework on trading book positions and capital requirements
- Update operational risk management frameworks to reflect changes to the Business Indicator and subcomponents
Key Dates
1 Jan 2027 Basel 3.1 rules take effect DEADLINE
1 Jan 2028 Internal model approach for market risk takes effect DEADLINE
Non-Compliance Risk
Non-compliance with the new rules may result in enforcement action, fines, or other regulatory penalties
Related Regulations
Basel 3.1Capital Requirements Regulation (CRR)Financial Services and Markets Act (FSMA) 2023
Confidence: high
BankBroker DealerAsset Manager
Policy statement 3/26
PS3/26 is the PRA's final policy statement restating the remaining provisions of the UK Capital Requirements Regulation (CRR) into the PRA Rulebook and related policy materials, effective 1 January 2027. This represents a critical step in the UK's transition away from assimilated EU law, consolidating fragmented regulatory requirements into a unified domestic framework while introducing targeted amendments to securitisation rules and External Credit Assessment Institution (ECAI) mapping.
What Changed
*Restatement of CRR Provisions**
The PRA is transferring remaining CRR requirements from the UK CRR into the PRA Rulebook without material changes to policy substance, except for targeted securitisation amendments. This follows the earlier PS12/25, which finalised the first tranche of restatement requirements in 2026.
*Policy Materials and Supervisory Guidance
PS3/26 introduces or amends multiple supervisory statements and statements of policy:
New: SS4/24 (Credit risk: Internal Ratings Based Approach), SS3/24 (Credit risk definition of default), SoP6/25 (Internal Model Method permissions),...
What You Need To Do
- *Immediate (by Q2 2026)
- *Review applicability
- *Assess impact
- *Identify policy changes
- *Medium-term (by Q3 2026)
Key Dates
20 January 2026 - PS3/26 final policy statement published
28 October 2025 - PS19/25 (near-final policy) published
1 January 2027 - All policies take effect; HM Treasury commencement regulations revoke relevant CRR provisions and replace them with PRA Rulebook rules and policy materials
Compliance Impact
Urgency: HIGH
The Prudential Regulation Authority (PRA) has published a policy statement (PS3/26) that restates the remaining relevant provisions in the Capital Requirements Regulation (CRR) within the PRA Rulebook and other policy materials. This change aims to ensure that the PRA's rules and policies are consistent with the UK's withdrawal from the EU. The policy statement is relevant to PRA-authorised banks, building societies, and other financial institutions.
What Changed
The PRA has restated the remaining relevant provisions in the CRR within the PRA Rulebook and other policy materials, including amendments to supervisory statements and the introduction of new statements of policy. The changes include updates to the securitisation requirements and the introduction of new rules on credit risk and internal ratings-based approaches.
What You Need To Do
- Review and update internal policies and procedures to ensure compliance with the restated CRR provisions
- Ensure that risk management practices are aligned with the updated rules on credit risk and internal ratings-based approaches
- Review and update securitisation policies and procedures to ensure compliance with the amended requirements
Key Dates
1 Jan 2027 The restated CRR provisions take effect DEADLINE
Non-Compliance Risk
Failure to comply with the restated CRR provisions may result in enforcement action, fines, or other regulatory penalties
Related Regulations
Capital Requirements Regulation (CRR)Basel 3.1Solvency II
Confidence: high
BankBroker DealerAsset Manager
Policy statement 4/26
PS4/26 finalizes the **simplified capital regime for Small Domestic Deposit Takers (SDDTs)**, a tailored prudential framework designed to reduce regulatory burden while maintaining capital resilience for smaller, domestically-focused UK banks and building societies. This represents the completion of Phase 1 of the PRA's "Strong and Simple" initiative and introduces materially lighter capital, liquidity, and reporting requirements for qualifying firms, with implementation effective January 1, 2027.
What Changed
*Simplified Capital Framework
The final policy introduces a dedicated capital regime** for SDDTs that descopes them from standard CRR Firms requirements. SDDTs are now subject to tailored Pillar 2 methodologies (SoP5/25) and simplified ICAAP/SREP processes (SS4/25) rather than the standard frameworks.
*Liquidity Simplifications
Qualifying SDDTs with 50% or more retail deposit funding** are exempted from the Net Stable Funding Ratio (NSFR) requirements, replacing this with a simpler Retail Deposit Ratio (RDR) measure.
What You Need To Do
- *Immediate (by January 20, 2026)
- *Assess SDDT eligibility – Determine whether your firm meets all seven qualification criteria, particularly the £20bn asset threshold and domestic asset location requirement
- *Review consolidation group structure – If part of a group, confirm which entity will serve as the SDDT consolidation entity responsible for certification
- *Implement SoP2/23 changes – Adopt updated operating procedures for the SDDT regime
- *Update ICAAP/ILAAP processes – Implement new frequency requirements for capital and liquidity adequacy assessments
Key Dates
January 20, 2026 – PS4/26 published; changes to SoP2/23 and ICAAP/ILAAP frequency requirements take effect
January 20, 2026 – Revocation of ICR firm/consolidation entity definitions and deletion of SoP3/23 effective
January 1, 2027 – Simplified capital regime for SDDTs takes effect; SS4/25 brought into effect in full; SDDTs removed from SS31/15 scope
Compliance Impact
Urgency: HIGH
The Prudential Regulation Authority (PRA) has introduced a simplified capital regime for Small Domestic Deposit Takers (SDDTs) to reduce regulatory complexity while maintaining adequate capital. The new regime will take effect on 2027-01-01. This change aims to simplify capital requirements for smaller banks and building societies.
What Changed
The PRA has introduced a new simplified capital regime for SDDTs, which includes changes to the PRA Rulebook, supervisory statements, and statements of policy. The regime also introduces new reporting templates and instructions.
What You Need To Do
- Review and update capital adequacy assessments to ensure compliance with the new simplified capital regime
- Implement new reporting templates and instructions for SDDTs
- Update internal policies and procedures to reflect changes to the PRA Rulebook, supervisory statements, and statements of policy
Key Dates
20 Jan 2026 Publication of the final policy statement
20 Jan 2026 Early implementation of changes to ICAAP updates and reverse stress-testing
1 Jan 2027 The SDDT capital regime takes effect DEADLINE
Non-Compliance Risk
Enforcement action, fines, or license revocation for non-compliance with the new simplified capital regime
Related Regulations
CRRBasel 3.1
Confidence: high
Bank
The FCA, Bank of England and Prudential Regulation Authority have together signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities to enhance cooperation and oversight of critical third parties (CTPs) that fall under the UK’s CTP regime.The MoU establishes a framework for coordinating and sharing information on the oversight of CTPs under the UK regime and critical third party providers (CTPPs) under the EU’s Digital Operational Resilience Act (DORA), including du...
The FCA, Bank of England (BoE), and Prudential Regulation Authority (PRA) have signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities (ESAs) to coordinate oversight of critical third parties (CTPs) under the UK's CTP regime and critical third party providers (CTPPs) under the EU's Digital Operational Resilience Act (DORA). This matters because it enhances cross-border information sharing and cooperation during incidents like cyber-attacks, reducing regulatory duplication while bolstering financial stability and operational resilience for firms reliant on these providers.
What Changed
Establishes a framework for timely information sharing, coordination of oversight activities, and joint responses to incidents affecting CTPs/CTPPs, including power outages or cyber-attacks.
Defines principles for cooperation on mutually designated CTPs/CTPPs, including notifications of investigations and best endeavors to share material information where legally and operationally feasible.
Complements the UK's CTP regime (effective 1 January 2025), which requires designated CTPs to provide regular assurance, conduct resilience testing, and report major incidents, without altering firms'...
What You Need To Do
- For CTPs/CTPPs
- For financial firms/FMIs
- Regulators' internal actions
- Firms should review contracts with third parties for compliance alignment and conduct gap analyses against CTP requirements
Key Dates
1 January 2025 UK CTP rules came into effect, applying to CTPs designated by HMT.
Ongoing (process begun pre-2025) HMT designation process for CTPs, with regulators recommending based on concentration and materiality criteria; no fixed end date specified.
DORA effective date (prior context) EU CTPPs oversight under DORA aligns with UK regime; MoU signed to ensure compatibility (exact DORA timeline not in publication but supports post-2024 implementation).
Compliance Impact
Urgency: High – The MoU operationalizes the live UK CTP regime (effective January 2025), with designations underway, amplifying risks of non-compliance for firms using critical ICT providers amid rising cyber and resilience threats. It matters for cross-border firms as it enables regulator-to-regulator data sharing, potentially exposing gaps in outsourcing arrangements and increasing enforcement scrutiny without fines on CTPs yet possible future powers.
BankPayment ProviderAll Firms
A growing number of investment schemes are being promoted unlawfully, are high risk and may even be scams. We've identified a growing number of investment schemes in holiday lodges and holiday homes being promoted to UK consumers by companies that are not FCA authorised.They may be unregulated collective investment schemes, where several investors invest their money. The schemes are being promoted unlawfully, are high risk and may even be scams. We remind consumers that if you invest in an un...
The FCA has issued a consumer warning about unregulated investment schemes in holiday lodges and holiday homes, which are often promoted unlawfully by unauthorised firms, posing high risks or outright scams. These schemes typically involve collective investments without FCA authorisation, breaching UK financial promotion and collective investment scheme (CIS) rules. This matters for compliance professionals as it signals heightened FCA scrutiny on unauthorised promotions, potential enforcement actions, and the need for firms to review marketing materials and client referrals to avoid facilitation risks.
What Changed
This is not a formal rulemaking or policy change but a consumer alert and enforcement signal under existing regulations. Key reminders include:
Unauthorised firms cannot lawfully promote collective investment schemes (CIS) under section 21 of the Financial Services and Markets Act 2000 (FSMA).
Holiday park schemes pooling investor funds for lodge purchases and management often qualify as unregulated CIS, making promotions illegal.
No new requirements are introduced, but the FCA emphasises its ongoing monitoring and willingness to intervene, including via the Financial Promotions Regime...
What You Need To Do
- Immediate verification
- Client communication review
- Training and monitoring
- Internal reporting
- Due diligence
Compliance Impact
Urgency: High. This alert indicates active FCA enforcement priority on consumer-facing scams in property-linked investments, with risks of fines, bans, or asset freezes for non-compliance (e.g., similar to past actions against mini-bond issuers). Firms face heightened supervisory visits or thematic reviews; inaction could lead to principal liability for facilitating unauthorised activities, especially post-2023 promotions regime. Prioritise within 30 days to align with FCA's "buyer beware" stance shifting to proactive gatekeeping.
Wealth ManagerAsset ManagerAll Firms
We confirm that the FCA has opened an investigation into WH Smith PLC. The investigation concerns potential breaches of UK Listing Principles and Rules and Disclosure and Transparency Rules in relation to the matters announced by WH Smith PLC on 19 November 2025.
The FCA has launched an investigation into WH Smith PLC for potential breaches of UK Listing Principles and Rules, as well as Disclosure and Transparency Rules (DTRs), stemming from announcements made by the company on 19 November 2025. This underscores the FCA's heightened scrutiny of listed companies' disclosure practices and adherence to market conduct standards. Compliance professionals should note this as a signal of enforcement risk in timely and accurate market disclosures, potentially setting precedents for similar cases.
What Changed
This is not a policy change or new rule; it is an enforcement investigation announcement with no immediate regulatory amendments. It highlights ongoing enforcement of existing rules:
UK Listing Principles and Rules: These require listed issuers to act with integrity, provide accurate and timely information, and maintain effective systems for compliance (e.g., Principle 2 on communication with investors; Listing Rule 9 on continuing obligations).
Disclosure and Transparency Rules (DTRs): Specifically, DTR 4 mandates inside information disclosures via Regulatory Information Service (RIS), DTR 5...
What You Need To Do
- For WH Smith PLC
- For other listed firms
- announcement sign-off processes involving legal/compliance/IR
- plan profit warnings or material updates, documenting decision trails
Key Dates
19 November 2025 - WH Smith PLC announcement triggering the investigation (reference point for alleged breaches).
late 2026 or 2027. Firms should monitor FCA updates via the specific URL or FCA enforcement news.
Compliance Impact
Urgency: High. This matters due to the FCA's aggressive enforcement posture on market abuse/disclosures (e.g., post-SPPF reforms emphasizing individual accountability). Breaches can lead to multimillion-pound fines (e.g., 10% of annual revenue), director bans, and reputational damage, amplified by public naming. For listed firms, it signals rising risk in a volatile economic environment where trading updates are frequent; non-compliance could cascade to shareholder claims or delisting risks.
All Firms
No description available.
The CFTC approved a final rule on December 18, 2025, that codifies existing staff no-action positions and eliminates duplicative business conduct and documentation requirements for swap dealers and major swap participants. This rule resolves over a decade of regulatory uncertainty, reduces operational costs, and harmonizes CFTC requirements with SEC and Municipal Securities Rulemaking Board standards.
What Changed
The final rule introduces the following substantive amendments:
*Exceptions for Swaps Intended to be Cleared (ITBC Swaps)**
Swap dealers and major swap participants are exempted from certain External Business Conduct Standards and swap trading relationship documentation requirements when executing swaps that are intended by the parties to be cleared contemporaneously with execution.
What You Need To Do
- *Immediate Actions (Pre-Implementation)
- *Implementation Actions (Upon Effective Date)
- trade disclosure systems to remove PTMMM generation and delivery requirements
- based operations, review implications of superseded Staff Letter No
- *Ongoing Compliance
Key Dates
April 4, 2025 - CFTC Staff Letter 25-09 issued, establishing no-action position on PTMMM requirement
September 12, 2025 - CFTC issued further amended exemptive order permitting JSCC to clear interest rate swaps
September 24, 2025 - CFTC issued Notice of Proposed Rulemaking (comment period opened)
October 24, 2025 - Comment period deadline (ISDA and SIFMA submitted comments on this date) DEADLINE
December 18, 2025 - CFTC approved final rule (subject to pre-publication technical corrections)
Compliance Impact
Urgency: HIGH
Broker DealerBank
We're expanding the significant work we had planned to improve standards in the home and travel insurance markets, following Which?’s super complaint. Read our response to Which? (PDF)While 79% of consumers who make an insurance claim are satisfied with how it was handled, our work shows there's room for improvement - with 3 in 10 (31%) saying there isn’t enough information to judge the quality of different policies. Over the next year, we will do more to: Improve claims handling, by reviewin...
The FCA is expanding its planned supervisory work in home and travel insurance markets in response to a Which? super complaint, focusing on improving claims handling, information provision, and overall standards. This matters for compliance professionals as it intensifies scrutiny under Consumer Duty, requiring firms to demonstrate better consumer outcomes amid ongoing simplification of insurance rules. It signals heightened FCA expectations for evidence-based improvements in customer satisfaction and transparency.
What Changed
This statement announces an expansion of existing planned work rather than new rules, with specific emphases over the next year on:
Improving claims handling through reviews of firms' processes.
Enhancing information available to consumers for judging policy quality (addressing the 31% dissatisfaction rate).
Building on prior simplification efforts, such as risk-based product reviews (replacing annual mandates), removal of prescriptive CPD requirements (e.g., 15 hours), and reduced data returns, as finalized in PS25/21.
No immediate new requirements are imposed, but firms must align with...
What You Need To Do
- Review and enhance claims handling processes to ensure efficiency and fairness, preparing evidence for FCA supervisory reviews
- Improve pre-sale information on policy quality, addressing gaps where 31% of consumers lack sufficient data
- Adopt risk-based product and distribution reviews (per PS25/21), documenting rationale for frequency based on harm risks; align with co-manufacturers
- Embed Consumer Duty via outcomes monitoring, data-driven MI on customer behavior/complaints, and vulnerability support; shift from process compliance to evidenced effectiveness
- Retain records, respond to FCA data requests, and invest in governance/MI for supervision
Key Dates
Over the next year (from publication, approx. late 2025) - FCA to conduct expanded reviews on claims handling, information provision, and standards improvement.
2026 - FCA to decide on changes to GAP insurance product-specific rules.
Q2 2026 - FCA consultation on removing non-UK customers from Consumer Duty scope, with parallel review of ICOBS and PROD application.
H1 2026 - FCA consultations on Consumer Duty amendments for distribution chains and UK customer focus.
September 2026 - Conduct Rules (COCON) expand to non-financial misconduct.
Compliance Impact
Urgency: High - This expands active FCA supervision in 2026, overlapping with Consumer Duty embedding and insurance simplification; non-compliance risks intensified reviews, enforcement, or redress schemes (as seen in motor finance). Firms gain flexibility but face accountability for outcomes, with scrutiny on data quality and vulnerability handling amplifying risks in a trust-based regime.
Insurance
The FCA welcomes the Government’s consultation on a new benchmarks regime for the UK. Since the introduction of the current regulatory framework, the financial landscape has evolved significantly. We now have an opportunity to build a regime that is more targeted to current market conditions and to reduce unnecessary burdens on industry, without compromising high standards. We are working with the Government to reform the current benchmarks regime to ensure that the regulatory framework remai...
The FCA welcomes HM Treasury's consultation on reforming the UK Benchmarks Regulation (BMR) to create a narrower, risk-based **Specified Authorised Benchmarks Regime (SABR)**, reducing regulatory scope by 80-90% to target only systemically important benchmarks and administrators while easing burdens on industry. This matters for compliance professionals as it shifts from broad regulation of all benchmarks to targeted oversight, requiring firms to reassess benchmark usage, prepare for transition, and adapt to FCA rules on risk management, enhancing UK competitiveness post-FSMA 2023 repeal of assimilated laws.
What Changed
Narrower scope: Regulation limited to benchmarks/administrators designated by HM Treasury (HMT) on FCA advice, based on criteria like systemic impact on UK financial integrity, consumers, or markets; reduces coverage by 80-90%, with no distinction between critical/significant/other types or benchmark categories (e.g., interest rate, commodity).
FCA-led firm-facing rules: HMT delegates requirements (governance, conflicts, oversight, methodology transparency, record-keeping) to FCA Handbook; removes legislative obligations on users to only use registered benchmarks, replaced by FCA...
What You Need To Do
- Review current benchmarks for potential designation risk (systemic impact criteria) and map usage across portfolios
- Participate in HMT consultation (responses via gov
- Develop/revise policies for benchmark risk management, including cessation/wind-down plans for regulated/non-regulated benchmarks per future FCA guidance
- Assess transition from current authorisation (if non-designated, prepare for deregistration); overseas firms evaluate ORR eligibility
- Update governance/conflicts frameworks for any designated activities; monitor ESG data inclusion in rules
Key Dates
17 December 2025 - HM Treasury publishes consultation on benchmarks regime reform.
1 January 2026 - Reforms take initial effect; UK becomes only jurisdiction regulating all local benchmarks pre-reform; EU BMR reforms effective, highlighting UK divergence.
Due course 2026 - FCA consults on regulatory requirements for designated administrators/users.
2026 - FCA expected to publish updated guidance on critical benchmarks and implement SABR refinements.
Compliance Impact
Urgency: High - Significant scope reduction eases burdens but introduces transition risks, new FCA rules, and designation uncertainty; firms must act now on consultation (post-Dec 2025) and prep for 2026 FCA changes to avoid non-compliance during shift, especially with 1 Jan 2026 milestone amplifying competitiveness pressures.
Asset ManagerBankBroker Dealer An update on our investigation into Mirabella Advisors LLP. On 4 May 2021, we announced that we had opened an investigation into the oversight of Greensill Capital Securities Limited, an appointed representative, by its principal, Mirabella Advisors LLP. Our investigation reviewed the nature, conduct and scope of Mirabella’s business. We did not identify breaches by Mirabella that require further action. The investigation has therefore now closed. Mirabella applied to have its authorisation c...
The FCA has closed its investigation into Mirabella Advisors LLP's oversight of its appointed representative (AR), Greensill Capital Securities Limited, finding no breaches warranting further action. This closure, announced after reviewing Mirabella's business nature, conduct, and scope, signals effective AR oversight in this high-profile case tied to the Greensill collapse, while Mirabella voluntarily cancelled its authorisation effective 12 September 2025. It matters for compliance professionals as it reinforces FCA expectations on principal-AR relationships without imposing new penalties or rules, but underscores ongoing scrutiny in trade finance and supply chain finance sectors.
What Changed
There are no new regulatory changes, requirements, or rules introduced by this publication. The statement solely announces the closure of an existing investigation with no identified breaches by Mirabella, maintaining the status quo on AR oversight obligations under FCA rules such as SUP 12 (Appointed Representatives). The FCA reserves the right to reopen if new information emerges, but no policy shifts or guidance updates are provided.
Key Dates
4 May 2021 - FCA announced opening of investigation into Mirabella's oversight of Greensill Capital Securities Limited as AR.
12 September 2025 - Mirabella's authorisation cancelled; firm no longer provides financial services.
Compliance Impact
Urgency: Low - This is a positive closure with no findings of misconduct, new rules, or enforcement, reducing immediate compliance burdens. It matters indirectly by exemplifying robust AR oversight meeting FCA standards amid Greensill fallout, offering reassurance for similar firms while signaling continued vigilance (e.g., potential reopening). Compliance teams should note it for precedent in AR due diligence but prioritize higher-risk areas like ongoing FCA trade finance financial crime probes.
Asset ManagerBroker DealerAll Firms
Policy statement 27/25
PS27/25 finalizes the PRA's policy to delete 37 redundant banking regulatory reporting templates (34 FINREP, 2 COREP, and PRA109) as the first phase of the Future Banking Data (FBD) programme, aiming to reduce reporting burdens while maintaining supervisory data quality. This matters for PRA-regulated banks as it delivers immediate cost savings and signals broader regulatory simplification, aligning with the PRA's secondary competitiveness and growth objective.
What Changed
Deletion of 37 whole reporting templates identified as duplicative, outdated, or low-value: 34 FINREP templates, 2 COREP templates (C05.01 and C05.02, now obsolete), and PRA109.
Consolidation of remaining FINREP scoping provisions into a single section of the PRA Rulebook (new Chapters 5A–5F of the Reporting (CRR) Part), with clarifications to unclear or duplicative conditions.
Alignment of FINREP remittance deadlines to 30 business days for reports under Article 430(3), Article 11(2), and new Chapters 5A–5F.
Updates to Supervisory Statement SS34/15 – Guidelines for completing regulatory...
What You Need To Do
- Review and update internal reporting systems, processes, and controls to cease submission of the 37 deleted templates for reference dates from 31 December 2025 onwards
- Confirm applicability of consolidated FINREP scoping rules (Chapters 5A–5F) and adjust scoping for remaining templates, incorporating clarified conditions
- Assess eligibility for individual FINREP waivers under the updated framework if part of a UK consolidation group; apply to PRA if criteria met (90-95% asset contribution)
- Update compliance policies and training to reflect SS34/15 amendments and aligned remittance deadlines
- Review Pillar 3 disclosure obligations for any ongoing requirements tied to deleted templates and prepare for potential future changes
Key Dates
8 December 2025 - Publication of PS27/25, finalizing policy and responses to CP21/25 consultation.
31 December 2025 - Effective date for revised rules, amended SS34/15, and deletions; applies to reporting reference dates falling on or after this date (avoids 2025 Q4 submissions where relevant).
11 November 2025 - Q3 2025 remittance deadline (precedes PS publication, so no concession for early non-reporting). DEADLINE
Compliance Impact
Urgency: Medium – Changes are simplificatory (deletions reduce burden), with immediate effect from 31 December 2025, but no new requirements or penalties for non-compliance with deleted items; firms must act promptly to decommission processes and avoid erroneous submissions. This matters as it lowers ongoing costs (especially for larger reporters) and sets precedent for FBD phases targeting further efficiencies, but smaller firms see limited benefit without broader reforms.
Bank
Policy statement 26/25
The Prudential Regulation Authority (PRA) has issued PS26/25, finalizing the withdrawal of Supervisory Statement (SS) 20/15, which previously set prescriptive expectations for building societies' treasury and lending activities, effective immediately upon publication on 5 December 2025. This deregulatory move reduces administrative burdens, enhances proportionality across deposit takers, and promotes competition by aligning building societies more closely with banks, while relying on existing tools like the PRA Rulebook, SMCR, and routine supervision for risk management. It matters for compliance teams as it eliminates specific guidance often misinterpreted as binding requirements, freeing firms to tailor risk frameworks but requiring vigilance on broader prudential expectations.
What Changed
Full deletion of SS20/15: Removes all expectations on treasury and lending activities, including the "Treasury Approaches" framework, without replacement.
Consequential amendments: Updates SS31/15 (Internal Capital Adequacy Assessment Process and Supervisory Review and Evaluation Process) to excise references to SS20/15.
Alignment with broader policy: Addresses inconsistencies with PRA's approach for banks, improved sector risk management maturity, and proportionality for smaller firms; supports objectives of safety, soundness, competition, and growth.
No new rules imposed: PRA deems existing...
What You Need To Do
- Review and update policies
- Assess risk management
- Update governance documents
- Engage supervisors
- Monitor related reforms
Compliance Impact
Urgency: Medium – Effective immediately (5 December 2025), but deregulatory nature reduces burdens rather than imposing new obligations; critical for year-end 2025/early 2026 planning to avoid legacy SS20/15 misapplication. Matters as it shifts from prescriptive "hard limits" (often treated as rules) to principles-based supervision, enabling flexibility but heightening reliance on firm-specific risk assessments amid PRA's focus on competition and growth; non-compliance risks arise from over-reliance on withdrawn guidance or inadequate tailoring.
Bank
Policy statement 25/25
PS25/25 is the PRA's policy statement providing feedback on CP10/25 and issuing updated Supervisory Statement SS5/25, which replaces SS3/19 to enhance banks' and insurers' management of climate-related financial risks through strengthened governance, risk management, scenario analysis, data quality, and disclosures. It matters because it sets a higher regulatory bar for embedding climate risks proportionately into core processes like ICAAP, ILAAP, ORSA, and financial reporting, promoting resilience and strategic decision-making amid evolving climate threats.
What Changed
The main changes in SS5/25 from SS3/19 and CP10/25 responses include:
Proportionate application clarification: New 'Overarching aims' section in Chapter 3 explains how firms should tailor expectations to their climate risk exposure, business size, and complexity via a two-step process (assess materiality, then respond).
Governance strengthening: Boards and senior management must actively oversee climate risks, embedding them in strategy and ensuring accountability.
Risk management enhancements: Integrate climate risks into existing frameworks/risk registers (supplementary sub-registers...
What You Need To Do
- Conduct gap analysis against SS5/25 within 6 months and remediate (e
- Integrate climate risks into board oversight, strategy, risk registers, ICAAP/ILAAP (banks), ORSA/stress testing (insurers), and financial reporting
- Perform CSA exercises commensurate with exposures, using suitable scenarios to inform decisions; enhance data quality and disclosures
- Document proportionate application (two-step process: materiality assessment, risk response); leverage existing structures where robust
- Ensure senior accountability and alignment with standards like SS1/21
Key Dates
3 December 2025 - PS25/25 and SS5/25 published; SS5/25 effective immediately, replacing SS3/19.
Within 6 months (by ~June 2026) - Firms assess gaps against new expectations and develop remediation plans (industry guidance).
Ongoing - Forward-looking, strategic implementation proportionate to risks; PRA may request progress evidence.
Compliance Impact
Urgency: High – Effective immediately (3 Dec 2025), requiring significant uplift to existing approaches; non-compliance risks supervisory scrutiny, as PRA expects ambitious, ongoing progress and may request evidence. Matters for capital/liquidity planning, resilience, and strategic viability amid maturing climate risk landscape.
BankInsurance
Policy statement 23/25
PS23/25 from the PRA and FCA finalizes amendments to Binding Technical Standards (BTS) 2016/2251 under UK EMIR, introducing an indefinite exemption for single-stock equity options and index options from bilateral margin requirements, removing IM obligations on legacy contracts for firms falling below thresholds, and allowing alignment with third-country jurisdictions' timelines for IM assessments. These changes reduce operational burdens and enhance competitiveness for UK firms trading non-centrally cleared derivatives, following feedback from CP5/25, while maintaining prudential standards.
What Changed
Indefinite exemption for equity options: Single-stock equity options and index options are permanently exempted from UK bilateral initial margin (IM) and variation margin (VM) requirements, replacing a temporary exemption ending 4 January 2026. This balances safety with international competitiveness, as capital can substitute for margin.
Legacy contracts relief: Firms falling below the Average Aggregate Notional Amount (AANA) threshold no longer need to exchange IM on outstanding legacy non-centrally cleared derivatives contracts.
Third-country alignment: UK firms can adopt another...
What You Need To Do
- Assess cross-border transactions
- Conduct gap analysis on margin calculations, collateral management, and reporting; train front-to-back office teams on changes
- Retain records of AANA calculations and threshold monitoring to justify exemptions or relief
- For firms with collected IM on now-exempt legacy positions, evaluate release options per updated FCA instrument language
Key Dates
11 August 2025 PRA submits final technical standards instrument to HM Treasury (HMT).
15 August 2025 FCA submits final technical standards instrument to HMT.
11 September 2025 HMT deems approval of PRA’s instrument.
24 September 2025 HMT deems approval of FCA’s instrument.
27 November 2025 Amendments to BTS 2016/2251 effective date.
Compliance Impact
Urgency: High – Effective immediately since 27 November 2025 (over a month ago as of current date), firms risk non-compliance if systems still enforce outdated IM/VM for exemptions; operational fixes are needed urgently to avoid breaches, fines, or disputes, especially with phase-out of temporary equity options relief approaching 4 January 2026. Impacts cost savings but requires swift policy recalibration for ongoing UK EMIR adherence.
BankBroker DealerAsset Manager
Policy statement 24/25
The PRA's PS24/25 finalizes rules increasing Financial Services Compensation Scheme (FSCS) depositor protection limits from £85,000 to £120,000 and temporary high balances (THB) from £1 million to £1.4 million for firm failures on or after 1 December 2025, responding to consultation feedback in CP4/25. This matters for PRA-authorized deposit-takers as it enhances consumer protection amid inflation but requires urgent system and disclosure updates to avoid FSCS payout delays or regulatory breaches. Firms must prioritize single customer view (SCV) readiness and phased disclosure revisions to comply efficiently.
What Changed
Increased Protection Limits: Standard FSCS deposit limit rises from £85,000 to £120,000; THB limit from £1 million to £1.4 million, applying to failures from 1 December 2025.
SCV System Updates: Firms must update SCV systems (used by FSCS for rapid compensation) to reflect new limits from 1 December 2025, including accurate contact details.
Disclosure Materials:
- Update information sheets on FSCS cover to reflect new limits and improve clarity/accessibility; provide to depositors as soon as practicable post-1 December 2025, by 31 May 2026.
- Revise compensation stickers/posters (for...
What You Need To Do
- Immediate (pre-1 Dec 2025)
- By 1 Dec 2025
- Post-1 Dec 2025 to 31 May 2026
- Document changes for audit trails; consider regtech for SCV automation
Key Dates
1 December 2025 - New deposit (£120,000) and THB (£1.4 million) limits apply to firm failures on/after this date; SCV systems must be updated; SS18/15 and SoP1/15 effective. DEADLINE
As soon as practicable after 1 December 2025 - Provide updated information sheets, stickers/posters, and exclusions lists to depositors (encouraged immediately to avoid confusion).
31 May 2026 - Firm deadline for all disclosure material updates and provision to depositors (six-month transition ends). DEADLINE
Compliance Impact
Urgency: High – SCV updates are mandatory by 1 December 2025 with no transition, risking delayed FSCS payouts and enforcement if unprepared; disclosure changes allow six months but PRA emphasizes early action to prevent depositor confusion. Impacts operational resilience and conduct risk; non-compliance could trigger supervisory action, especially for firms with outdated systems. Cost-benefit analysis shows minimal PRA impact but higher potential FSCS payouts in failures.
Bank
Policy statement 22/25
The PRA's PS22/25 finalizes an increase in the retail deposits threshold for the leverage ratio requirement from £50 billion to £75 billion, introducing a three-year averaging mechanism for calculations, effective 1 January 2026. This adjustment reflects nominal UK GDP growth since 2016 to maintain the Financial Policy Committee's original risk appetite while smoothing cliff-edge effects for firms like building societies. It matters for major UK banks and similar firms as it alters capital planning and leverage ratio applicability, potentially reducing immediate compliance burdens for those nearing the old threshold.
What Changed
Retail deposits threshold raised from £50 billion to £75 billion, adjusted upward from the CP2/25 proposal of £70 billion to account for further GDP growth to Q2 2025 (rounded to nearest £5 billion).
Introduction of a three-year moving average for calculating retail deposits metric, replacing point-in-time values to mitigate volatility and aid capital planning, particularly for building societies.
Non-UK assets threshold remains unchanged at £10 billion.
Modifications by consent disapplying leverage ratio rules during review will cease on 30 June 2026.
These changes are implemented via...
What You Need To Do
- Review and update internal retail deposits calculations to incorporate three-year moving average methodology starting 1 January 2026
- Assess current and projected retail deposits against £75 billion threshold (and £10 billion non-UK assets) to determine leverage ratio applicability and adjust capital planning accordingly
- Prepare to meet 3
- For firms with modifications by consent
- Update governance, risk models, and board reporting to reflect changes; conduct gap analysis against PRA Rulebook appendices in PS22/25
Key Dates
5 March 2025 - PRA publishes Consultation Paper CP2/25 proposing £70 billion threshold.
5 June 2025 - Consultation response deadline. DEADLINE
12 November 2025 - PRA issues PS22/25 with final policy.
1 January 2026 - Final policy takes effect, applying new £75 billion threshold and three-year averaging.
30 June 2026 - Cessation of modifications by consent disapplying leverage ratio rules.
Compliance Impact
Urgency: High – With effectiveness just after today (1 January 2026), firms near £50-75 billion in retail deposits face immediate recalibration of leverage exposures and capital buffers to avoid breaches, amplified by the shift to averaging which requires historical data reconstruction. Non-compliance risks PRA enforcement, heightened scrutiny, or capital inadequacy findings, but the higher threshold and averaging provide planning relief versus the status quo.
BankPayment ProviderAll Firms
The Financial Policy Committee (FPC) welcomes today the Prudential Regulation Authority’s (PRA’s) policy statement 20/25 – The Strong and Simple Framework: The simplified capital regime for Small Domestic Deposit Takers (SDDTs) – near-final.
The Financial Policy Committee (FPC) welcomes the Prudential Regulation Authority's (PRA) Policy Statement (PS) 20/25, which finalizes the second phase of the "Strong and Simple Framework" by introducing a simplified capital regime for Small Domestic Deposit Takers (SDDTs), alongside liquidity simplifications. This matters because it reduces regulatory burdens, enhances competition among smaller UK banks and building societies, and maintains resilience without full Basel 3.1 standards, with implementation on 1 January 2027.
What Changed
Pillar 1 simplifications: Adoption of Basel 3.1 standardised approaches to credit and operational risk; disapplication of due diligence for credit risk, simplifications to market risk, removal of counterparty credit risk and CVA requirements for derivatives (with exceptions), and adjustments to Leverage Ratio and Large Exposures.
Pillar 2A methodologies: Simplifications for credit risk, credit concentration risk (CCoR), and operational risk; amendments to single-name concentration monitoring (cluster limit tightened to 200%, excluding credit institutions); full deduction for certain...
What You Need To Do
- Assess SDDT eligibility
- Update capital frameworks
- ICR transitions
- Policy and process revisions
- Supervisory engagement
Key Dates
17 January 2025 Deadline for comments on related CP14/24. DEADLINE
28 October 2025 Publication of near-final PS20/25.
1 January 2026 Full Basel 3.1 standards apply to ICR opt-in firms (ICR revoked); some changes to SoP2/23, ICAAP/ILAAP update frequencies effective from PS4/26 publication.
20 January 2026 Publication of final PS4/26 confirming PS20/25; effective date for ICAAP/ILAAP updates (including reverse stress-testing).
1 January 2027 Simplified capital regime for SDDTs takes full effect.
Compliance Impact
Urgency: High – With full implementation on 1 January 2027 (less than 12 months from today), SDDTs face tight timelines for capital recalibrations, ICR exits, and reporting overhauls; missing deadlines risks supervisory intervention or full Basel 3.1 compliance costs. This significantly eases burdens (e.g., simpler buffers, reduced reporting) but requires proactive gap analysis to leverage simplifications while ensuring resilience.
BankFintech
Policy statement 19/25
**PS19/25** is the PRA's near-final policy statement finalizing how remaining Capital Requirements Regulation (CRR) provisions will be restated into the PRA Rulebook, effective January 1, 2027. This represents a critical step in the UK's transition away from assimilated EU law, giving the PRA expanded rule-making authority over UK banks, building societies, and investment firms while introducing targeted policy changes to securitisation, credit risk treatment, and ECAI mapping.
What Changed
The near-final policy confirms and finalizes the following substantive amendments:
*Securitisation Requirements**
Largely preserves current requirements and supervisory expectations with targeted policy changes
Introduces a new formulaic p-factor for the standardised approach to securitisation
Establishes new capital rules for certain mortgage exposures
Clarifies supervisory expectations for unfunded credit protection in synthetic Significant Risk Transfer (SRT) securitisations by adding expectations to SS9/13
*Level of Application of CRR Requirements**
Restates rules relating to level of...
What You Need To Do
- *Review the final policy statement when published in Q1 2026 to understand specific rule changes applicable to your firm's business model
- *Assess securitisation impacts
- *Evaluate mortgage capital treatment
- *Update ECAI mapping processes
- *Establish implementation timeline
Key Dates
28 October 2025 - PRA published near-final policy statement PS19/25
Q1 2026 - PRA intends to publish final policies and rule instruments alongside or shortly after final Basel 3.1 package publication
1 January 2026 - Implementation date for certain proposals finalized in PS12/25 (limited scope)
1 January 2027 - Implementation date for policies and requirements in PS19/25 (primary implementation date)
Compliance Impact
Urgency: HIGH
BankBroker Dealer
Policy Statement 20/25
**PS20/25** represents the second and final phase of the PRA's "Strong and Simple Framework," establishing a significantly simplified capital regime for Small Domestic Deposit Takers (SDDTs) while maintaining their resilience. This near-final policy statement, published on 28 October 2025, fundamentally restructures capital requirements, liquidity rules, and operational frameworks for SDDTs—a critical development for smaller deposit-taking institutions seeking regulatory relief from disproportionate compliance burdens.
What Changed
The simplified capital regime introduces structural changes across all three pillars of capital requirements:
*Pillar 1 (Risk-Weighted Assets)
SDDTs must apply Basel 3.1 standardised approaches for credit risk and operational risk, with specific simplifications.
Due diligence requirements in the standardised approach to credit risk are disapplied for SDDTs.
Counterparty credit risk (CCR) for derivatives and credit valuation adjustment (CVA) risk are disapplied (with minor exceptions).
Market risk framework is simplified, with SDDTs applying the credit risk approach to trading book positions...
What You Need To Do
- *For SDDTs Currently Operating or Considering Entry:
- *Notification Decision – Determine whether to enter the SDDT regime and submit notification to the PRA by 31 March 2026 if seeking to benefit from simplified rules
- *Policy Review – Conduct comprehensive review of PS20/25, related policy statements (PS18/25, PS19/25, PS8/25, PS14/25), and supporting methodologies (SoP5/25, SS4/25, amendments to SoP2/23)
- *Capital Calculation Transition – Prepare systems and processes to transition from current capital calculation methodologies to Basel 3
- Removal of CCR and CVA calculations for derivatives
Key Dates
31 March 2026 – Deadline for firms wishing to enter the SDDT regime to notify the PRA and benefit from the simplified framework at implementation. DEADLINE
1 January 2027 – Implementation date for the simplified capital regime for SDDTs; the Interim Capital Regime will no longer apply.
2026 (specific date TBD) – PRA to make final rules and policy covering the entire Basel 3.1 package once HM Treasury makes commencement regulations to revoke relevant CRR provisions.
2027 (specific date TBD) – PRA to implement restatement of CRR requirements (PS19/25).
Compliance Impact
Urgency Rating: HIGH
Bank
Policy statement 17/25
PS17/25 establishes the **Matching Adjustment Investment Accelerator (MAIA) framework**, enabling PRA-regulated insurers to regularize and expand their use of matching adjustment (MA) in calculating capital requirements for certain long-duration insurance liabilities. This framework is significant because it provides a structured pathway for firms to optimize capital efficiency while maintaining prudential safeguards through exposure limits, eligibility assessments, and breach remediation mechanisms.
What Changed
The MAIA framework introduces the following regulatory requirements:
*Permission and Eligibility Framework
Firms must obtain explicit MAIA permission** from the PRA to use the accelerator
Permission grants authority to regularize previously non-compliant MA assets and apply MA to new eligible assets within defined parameters
*Exposure Limits
Firms receive fixed monetary exposure limits** calibrated using the Best Estimate of Liabilities (BEL) of the MA portfolio, net of reinsurance, at the time of permission grant
Limits remain fixed until the next formal variation of MAIA...
What You Need To Do
- *Immediate (Q4 2025 - Q1 2026)
- *Assess eligibility for MAIA permission by reviewing current MA portfolio and prospective assets
- *Develop MAIA policy documenting asset eligibility criteria, governance structure, and risk management approach
- *Establish contingency plans for scenarios where MAIA assets become ineligible
- *Prepare MAIA permission application if pursuing the framework
Key Dates
27 October 2025 - PS17/25 final rules and policy material took effect; firms could begin applying for MAIA permission
31 December 2026 - Implementation deadline for changes to MALIR reporting template DEADLINE
18 weeks after financial year-end - Annual MAIA use report submission deadline (ongoing, annually) DEADLINE
2 months from breach identification - Deadline to rectify breaches to avoid MA benefit reduction DEADLINE
Compliance Impact
Urgency: HIGH
Insurance
Policy statement 21/25
PS21/25 implements reforms to PRA remuneration rules for banks, building societies, and PRA-designated investment firms, simplifying Material Risk Taker (MRT) identification, aligning deferral periods with international standards (4 years for non-SMF MRTs and 5 years for SMFs), and enhancing links to individual accountability under the Senior Managers Regime (SMR). These changes matter as they reduce regulatory burden, increase flexibility in bonus structures (e.g., marginal deferral rates and cash payments), and promote competitiveness while maintaining risk alignment, potentially reversing trends toward higher fixed pay.
What Changed
MRT Identification: Simplified quantitative threshold to the top 0.3% of earners (assessed against risk impact); qualitative criteria unchanged; raised proportionality threshold for disapplying rules from £44,000 variable pay to £660,000 total pay (with variable pay ≤33% of total); reintroduced exemption for MRTs serving <3 months.
Deferral Periods: 4-year minimum for non-SMF MRTs (previously varied); reduced to 5 years for SMFs (from 7 years); aligns with FCA and international practice.
Deferral Rates: Marginal system—40% deferral on first £660,000 of variable remuneration, 60% above;...
What You Need To Do
- Review and update MRT identification processes, applying simplified top 0
- Revise remuneration policies for deferral (4/5 years, marginal rates), upfront cash flexibility, and instrument expectations; update bonus award calculations
- Embed SMR-linked adjustments
- For dual-regulated firms
- Optional early adoption for specified changes on 2025/unvested awards; document governance for RemCo approvals and board policies
Key Dates
15 October 2025 Publication date; some changes (e.g., deferral periods, pro-rata vesting) may apply to ongoing 2025 performance year and unvested prior awards at firm discretion.
16 October 2025 Final rules and updated SS2/17 take effect; apply to performance years starting after this date (e.g., mandatory from 1 January 2026 for calendar-year firms).
November 2024 Preceding joint consultation (CP16/24/PRA, CP24/23/FCA) closed prior to PS.
Compliance Impact
Urgency: High – Mandatory from performance years post-16 October 2025 (e.g., 2026 for most), with immediate opt-in possible; impacts 2026 bonus cycles, requiring swift policy rewrites amid year-end planning. Matters due to simplified but ownership-heavy MRT processes, SMR-pay linkages raising accountability risks, and flexibility needing robust justification to avoid supervisory challenge; non-compliance risks enforcement under PRA accountability regimes.
BankAsset ManagerAll Firms
Policy statement 16/25
PS16/25 is the PRA's policy statement restating firm-facing organisational requirements from the MiFID Org Reg (e.g., outsourcing, record-keeping, risk management, compliance, internal audit, and governance) into the PRA Rulebook, with no material changes, to align with HMT's revocation of the EU regulation under FSMA 2023. This matters because it ensures continuity of prudential oversight for PRA-authorised firms post-revocation, preventing enforcement gaps in systems and controls while adapting provisions (e.g., supervisory function) to UK governance structures.
What Changed
Restatement of requirements: Provisions from MiFID Org Reg Articles on outsourcing, record-keeping, control procedures, risk management, compliance, internal audit, and governance are transferred verbatim or with minor clarifications into PRA Rulebook parts (e.g., Risk Control).
Supervisory function adjustment: Following consultation feedback, PRA retained Article 25 provisions but substituted "governing body" for "supervisory function" to fit UK firm structures, preserving board-level oversight without substantive change.
Technical standards update: Minor amendment to algorithmic trading...
What You Need To Do
- Review and map existing MiFID Org Reg compliance processes against restated PRA Rulebook provisions (e
- Confirm governing body oversight aligns with adapted Article 25 requirements; document any adjustments for UK structures
- Update internal references in algorithmic trading governance documents to new rule 2
- Conduct gap analysis and training on minor clarifications; prepare for dual FCA/PRA alignment if applicable
- Monitor HMT commencement order; if delayed, reassess implementation plans
Key Dates
9 October 2025 - PRA publishes PS16/25 with final rules and feedback to CP9/25 consultation.
23 October 2025 - New PRA rules and technical standards come into force, coinciding with HMT's anticipated revocation of MiFID Org Reg via commencement order (FCA rules align on same date).
Prior to 23 October 2025 - HMT expected to lay second Statutory Instrument revoking remaining MiFID Org Reg provisions; PRA may delay/revoke rules if not made.
Compliance Impact
Urgency: High – Firms must act promptly as rules take effect on 23 October 2025 (past deadline as of current date), with no transition period; non-compliance risks enforcement gaps in core systems/controls post-revocation. Impact is low for substance (restatement only) but requires documentation updates to avoid supervisory scrutiny, especially for governance and outsourcing.
BankBroker DealerAll Firms
Policy statement 15/25
PS15/25 introduces **new liquidity risk reporting requirements for major UK insurance firms**, closing data gaps identified during the March 2020 "dash for cash" and September 2022 LDI crisis. The policy mandates four new reporting templates for firms with significant derivatives or securities lending exposure, with implementation deferred to **30 September 2026** to allow adequate preparation time.
What Changed
The PRA's final policy establishes the following regulatory framework:
*New Reporting Templates**
Four new liquidity reporting templates have been introduced to capture previously unavailable data:
Annual committed facilities template
Monthly cash-flow mismatch template (short form)
Monthly cash-flow mismatch template for ring-fenced funds, matching adjustment portfolios, and remaining parts
Additional supervisory reporting requirements
*Scope and Thresholds
Firms are subject to liquidity reporting if they meet both of the following conditions:
Gross notional value of derivatives contracts...
What You Need To Do
- *Immediate Actions (by Q2 2026)
- *Threshold Assessment
- *RFF Mapping
- *System Readiness
- *Data Governance
Key Dates
30 September 2025 - PRA published PS15/25 (policy statement)
31 December 2025 - Original implementation deadline (now superseded) DEADLINE
30 September 2026 - **Final implementation date for all liquidity reporting requirements**
First reporting reference date after 30 September 2026 - Firms meeting threshold conditions must commence reporting DEADLINE
Three consecutive annual reporting reference dates - Threshold for ceasing reporting once firms fall below thresholds
Compliance Impact
Urgency: HIGH
Insurance
Asset management The AMF has postponed the effective date of the authorisation withdrawal of the asset management company Nestadio Capital
The Autorité des Marchés Financiers (AMF) postponed the effective date of the authorization withdrawal for Nestadio Capital, a portfolio asset management company, to allow time for fund transfers or liquidation following repeated non-compliance with authorization terms. This matters for compliance professionals as it illustrates AMF's enforcement approach to regulatory breaches in asset management, emphasizing orderly wind-downs to protect investors while signaling risks of judicial intervention if issues persist. The case culminated in judicial liquidation by 2022, highlighting long-term consequences for non-compliant firms.
What Changed
Initial authorization withdrawal decided on 17 December 2019 due to Nestadio Capital's failure to comply with authorization terms, including capital requirements, with original effective date at the latest 1 July 2020 (or upon fund transfer/liquidation).
Multiple postponements: 9 June 2020 and 8 December 2020 extended to 30 June 2021; 8 June 2021 further extended to 31 December 2021 to facilitate fund sales and liquidation.
7 December 2021 postponement tied withdrawal effect to full fund liquidation or judicial liquidation closure, triggered by commercial court judgment on 17 December 2021...
What You Need To Do
- For Nestadio Capital (historical)
- For investors
- For industry peers
- AMF referrals to courts underscore need for firms to self-report issues early to avoid escalation
Key Dates
17 December 2019 - AMF Board decides authorization withdrawal.
1 July 2020 - Original latest effective date for withdrawal (or fund transfer/liquidation).
9 June 2020 & **8 December 2020** - Postponements to **30 June 2021**.
8 June 2021 - Postponement to **31 December 2021** for fund sales/liquidation.
4 October 2021 - Conseil d'Etat rejects Nestadio's appeal.
Compliance Impact
Urgency: low - This is a resolved 2019-2022 enforcement case with no ongoing deadlines or new rules as of 2026; Nestadio is in judicial liquidation. It matters as a precedent for AMF's phased withdrawal process, protecting investors via extensions and liquidators, but warns asset managers of severe outcomes for breaches like capital shortfalls—review governance and capital monitoring to mitigate similar risks.
Asset Manager